Associated Enterprises. Where (a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or (b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State,
Appears in 7 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Associated Enterprises. Where
(a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State,
Appears in 6 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Associated Enterprises. Where
(a) an enterprise of a Contracting State one of the States participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State one of the States and an enterprise of the other Contracting State,
Appears in 4 contracts
Samples: Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Associated Enterprises. Where
(a) an enterprise of a one of the Contracting State States participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, ; or
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a one of the Contracting State States and an enterprise of the other Contracting State,
Appears in 2 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement
Associated Enterprises. Where
(a) an enterprise of a Contracting State one of the States participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State one of the States and an enterprise of the other Contracting State,
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Associated Enterprises. 1, Where:
(a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State,
Appears in 2 contracts
Samples: Botswana Ireland Double Taxation Avoidance Agreement, Botswana Ireland Double Taxation Avoidance Agreement
Associated Enterprises. Where
(a) an An enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(b) the The same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State,
Appears in 1 contract
Associated Enterprises. 1. Where:
(a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, ordirectly...
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of 2. Where a Contracting State and an enterprise includes in the profits of the other Contracting State,an...
Appears in 1 contract
Samples: Double Taxation Relief Agreement
Associated Enterprises. Where
(a) an a. An enterprise of a Contracting State one of the States participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(b) the b. The same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State one of the States and an enterprise of the other Contracting State,
Appears in 1 contract
Associated Enterprises. Where
(a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State,. accordingly.
Appears in 1 contract
Associated Enterprises. Where
(a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State,
Appears in 1 contract
Associated Enterprises. Where
(a) an An enterprise of a Contracting State one of the States participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(b) the The same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State one of the States and an enterprise of the other Contracting State,
Appears in 1 contract
Associated Enterprises. Where
(a) a. an enterprise of a Contracting State one of the States participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(b) b. the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State one of the States and an enterprise of the other Contracting State,
Appears in 1 contract
Associated Enterprises. Where:
(a) an enterprise of a one of the Contracting State States participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, ; or
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a one of the Contracting State States and of an enterprise of the other Contracting State,;
Appears in 1 contract
Associated Enterprises. Where
(a) an enterprise of a one of the Contracting State States participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, ; or
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State,
Appears in 1 contract
Samples: International Tax Agreements
Associated Enterprises. WhereWhere -
(a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State,
Appears in 1 contract
Associated Enterprises. Where
(a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, ; or
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State,
Appears in 1 contract
Samples: International Tax Agreements
Associated Enterprises. Where
(ai) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(bii) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State,
Appears in 1 contract
Associated Enterprises. Whereo
(a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, ; or
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State,
Appears in 1 contract
Associated Enterprises. Where
(a) an enterprise of a Contracting State one of the States participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State one of the States and an enterprise of the other Contracting State,, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made
Appears in 1 contract
Associated Enterprises. Where:
(a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State,
Appears in 1 contract
Associated Enterprises. Where
(a) an enterprise of a Contracting State Party participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting StateParty, or
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State,
Appears in 1 contract
Samples: Double Tax Agreement
Associated Enterprises. Where:
(a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, ; or
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State,
Appears in 1 contract
Associated Enterprises. Where:
(a) an An enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(b) the The same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State,.
Appears in 1 contract
Associated Enterprises. Where:
(a) an An enterprise of a Contracting State one of the States participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
(b) the The same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State,
Appears in 1 contract
Associated Enterprises. Where
(a) an An enterprise of a Contracting State one of the States participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or,
(b) the The same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State one of the States and an enterprise of the other Contracting State,
Appears in 1 contract
